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Headquarters Office

Related Content: Administrative Office; Offshore Vehicles
 

Headquarters offices are offices situated abroad to exercise certain management, co-ordination, and control functions for the sole or principal benefit of an enterprise or group. Headquarters offices may benefit from a favourable tax regime even in an otherwise high tax jurisdiction. The competition between these countries is resulting in the de facto introduction of more and more favourable tax regimes through what may amount to a partial system of unpublished revenue rulings.

 
 
 
 
 
 

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Private Banking

The core activity of private bankers traditionally has been and still is asset management for offshore and onshore private clients. Private banking is not only performed by private bankers. Many former private bankers have converted their partnerships into private or publicly traded corporations in order to have limited liability and to be able to benefit from financing opportunities on the onshore and offshore capital markets.
 

Choice of Law in International Tax Planning

Choice of law is a conflict of laws (private international law) issue, and the rules are part of the domestic law of each country. Choice of law problems frequently arise with respect to entities that are not known to, or do not enjoy legal personality in, a foreign system. The determination of the applicable law for the purpose of characterising such entities varies from one legal system to another, a point to be watched in the design of an international tax plan.
 

Transfer Pricing Calculations

Alternative methods, recommended by the Revenue or prescribed by the law, include: (a) the comparable uncontrolled price (CUP) method; (b) the resale price method; (c) the cost-plus method; (d) the mixture of basic methods; (e) the profit comparison; (f) the return on capital invested method; (g) the profit split method; and (h) the unitary method.
 

Captive Insurance Companies

A captive insurance company is an insurance company that is fully owned (directly or indirectly) by a non-insurance commercial company and exclusively insures or reinsures the risks of the parent company and/or its affiliated companies. The function is thus one of self-insurance from the group point of view. The underlying reasons for the formation of foreign captive insurance companies are usually of an insurance and business nature quite apart from any fiscal benefits that may accrue in an international tax plan. Foreign captive insurance companies are located in a certain number of tax havens or international offshore financial centers (IOFCs), in particular, in Bermuda, the Bahamas, the Cayman Islands, Guernsey, Hong Kong, the Isle of Man, Jersey, Panama, and Vanuatu.
 
 
 
 
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